From: Mitchell Feuer [mitchell.feuer@rfgdc.com]
Sent: Friday, March 26, 2004 4:09 PM
To: 'rule-comments@sec.gov'
Cc: Sapna Patel (E-mail)
Subject: S7-10-04 - Request to Testify:
Summary of intended testimony
On behalf of Reuters America, I would like to provide the following summary of
the testimony that Reuters hopes to provide at one of the public hearings on
Regulation NMS. Reuters witness would be Phil Lynch, chief executive of Reuters
America. Mr. Lynch would focus on the market data proposals, including the
consolidated display requirements and the ability of broker-dealers to sell
their data, and the prohibition on sub-penny pricing.
Reuters would be generally supportive of the proposals to reduce the requirement
to provide consolidated display to the prize, size, and market identifier of the
NBBO, with last sale data; to require consolidated display only in contexts
where trading or order-routing decisions could be implemented - not in purely
information contexts; to allow broker-dealers to distribute their own data,
such as depth of limit order book, independently, with or without fees; and to
require broker-dealers distributing data for which they are the sole source to
make that information available to information processors on terms that are fair
and reasonable and not unreasonably discriminatory; and to establish advisory
committees for the market data plans. Reuters might also offer suggestions for
additional flexibility that could be allowed under the market data rules.
Reuters also would be generally supportive of the proposal to prohibit sub-penny
pricing. Reuters can explain how sub-penny pricing increases quote traffic,
creates strains on market data systems capacity, and may not be transparent to
all investors.
Please forward all questions and communications regarding this request and
summary of intended testimony to:
Mitchell Feuer
Rich Feuer Group
1133 Connecticut Ave., NW
Fifth Floor
Washington, DC 20036
(202) 429-6881
fax (202) 457-1130
mobile (202) 277-1077